Massachusetts regulations promote forest harvesting for biomass fuel

Published September 20, 2011

[Click here for a detailed letter on problems with the Massachusetts regulations.]

When the State of Massachusetts issued draft regulations last spring to restrict eligibility of low-efficiency biomass power for renewable energy credits, scientists and activists lauded the action. The regulations weren’t perfect, but they basically incorporated the findings of the state-commissioned Manomet Study, which found that when trees are burned for fuel in biomass electricity plants, the net carbon emissions over a period of more than 40 years are greater than those from coal – even taking forest carbon sequestration into account.

The draft regulations had three main components to help reduce the greenhouse gas impact of using wood for fuel:

1.“Eligible” biomass fuel is restricted to no more than 15% of the wood from any particular harvest (the biomass industry often claims that they only use “residues” for fuel – that is, the tops and branches left over after commercial sawtimber harvesting. These materials make up about 50% the mass of a tree, thus harvesting one-half of this material amounts to 15% of the harvested trees. So this provision simply confirms what the industry often claims, anyway).

2.Facility efficiency must be at least 40% to be eligible for one-half a renewable credit per megawatt-hour, and 60% to be eligible for a full credit. That’s a standard that encourages combined-heat-and-power facilities because it allows useable thermal energy production to count toward renewable energy credits – even though these are currently only granted for electricity production.

3.Estimated over a 20-year period, the net greenhouse gas emissions of a biomass-burning facility can be no greater than 50% of the emissions from a natural gas facility. Massachusetts’ Global Warming Solutions Act mandates the state to reduce greenhouse gas emissions 20% below 1990 levels by 2020, and 80% by 2050. The state won’t get there, though, by promoting “renewable” energy that emits more CO2 than the fossil fuels it’s meant to replace. This provision would help prevent that.

Predictably, the biomass industry had a meltdown when the draft regulations were released, claiming that the standards were impossible to meet. And then the real lobbying began. According to public records, the biomass industry spent hundreds of thousands of dollars to lobby the Massachusetts Department of Energy Resources.

When the dust settled, a key provision of the regulations limiting eligible biomass to 15% of harvested wood was replaced by a provision allowing 40% of a harvest to be burned and considered essentially “carbon free” – because under the carbon accounting framework that was released with the regulations, all wood, even whole trees, is treated as if is logging residues and has little net impact on carbon emissions (for a more detailed explanation of the problems in the regulations, click here).

With this provision, the regulations essentially gutted the key finding of the Manomet Study out of the Massachusetts framework. Manomet demonstrated what the average person on the street understands immediately, that growing trees remove CO2 from the atmosphere, but this process takes time. Burning those trees instantly adds greenhouse gases to the atmosphere – there’s nothing “carbon neutral” about this process.

By pretending that cutting and burning whole trees doesn’t add carbon to the atmosphere, the newly watered-down Massachusetts regulations claim the legitimacy of being “based on Manomet” – while ignoring that study’s key finding. The science-based process of which the state could have been justly proud has been undone at the last minute by heavy industry pressure. The latest version of the regulations can still be changed, and the scientists and citizens watchdogging the regulations await the restoration of integrity to this process.